Last month, Judge Koh ruled that Samsung did not willfully infringe on Apple's patents; however, did not grant the company a new trial as it had requested.

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Update:Bloomberg reports that Koh said Samsung deserves a new trial on infringement claims over its Galaxy Prevail and other smartphones. Koh rejected Apple’s request to enhance the jury’s award, saying the amount Samsung owed was heavily disputed and the jury wasn’t bound to accept either side’s damages estimate.

“It is not the proper role of the court to second-guess the jury’s factual determination as to the proper amount of compensation,” Koh said.